OK wine industry folks, let’s clear this up once and for all.
When a TTB label approval (COLA) is required for the bottling of a wine who is the responsible party?
A. The winery that bottles the wine
B. The winery that bottles the wine
C. The winery that bottles the wine
D. All of the above
That’s it folks, always has been. It is always, always, always the winery that bottles/bottled a wine that is responsible for obtaining the TTB label approval for it.
- It does not matter that a wine was bottled without labels (shiners!) then is later labeled by another winery site.
- It does not matter if you are an alternating proprietor that your wine is bottled by your host winery that you are sharing the same winery site with.
- It does not matter that you already have a COLA for a wine bottled at one winery site and the next year that wine is bottled at a different winery site.
Plain and simple if a wine is going to be bottled, and it will be bottled at a winery site that has never bottled it before then a new TTB label approval will be required to be filed for it by the new winery site.
Plain and simple if a wine was bottled without labels, then shipped to another winery or wine cellar facility and sometime later a label is designed for that wine and will be placed on the bottles by the second winery (or wine cellar) site they will have to reach out directly to the bottling winery to have them submit the labels for TTB label approval. (Side note here- they will also need to make sure that the wine details listed on those labels match the actual wine blend for items such as vintage, varietal, appellation and alcohol content)
I see or hear so much confusion about this topic which often turns into some real hassles for winery staff and business owners. Definite inconvenient hassles such as having to reprint labels (think major additional business expense here too), or having to cancel or reschedule their bottling date.
Wineries, alternating proprietors, wine cellars- Don’t let this happen to you! When a bottling for one of your wines is coming up automatically ask the question, Will it be bottled at our winery site or at another one? By the way further clarification- when I say at your winery site I mean under your TTB permit- because that is the true source of what any label approval backs into.
For any of you who are alternating proprietors – this means will you bottle the wine under your TTB permit or under the host winery’s TTB permit that you share space with?
If you have any clarification questions on this commonly misunderstood topic in our industry- you are a candidate for one of my Compliance Check In calls.
You can schedule one here: Compliance Check in